Expert testimony for state compliance advisories and city council hearings

Management of all state-specified attainment and nonattainment permitting oversight

Management of permit conditions and report/recordkeeping requirements for local, state and federal agencies

Let CGRS help you navigate all of the requirements that may be applicable for each one of your sites, so you can have confidence in your regulatory air-compliance program.

State & Federal Air Permitting

Major and Minor Source Permits
Sources can be classified as major, synthetic minor, or true minor. A major source has a potential to emit (PTE) greater than 100 tons per year (TPY) of volatile organic compounds (VOCs) and specific regulatory thresholds for hazardous Air Pollutants (HAPs). A synthetic minor source has a PTE greater than specified regulatory thresholds, but accepts permit conditions that control emissions to keep it minor. A true minor has a PTE less than specified regulatory thresholds in all categories. As an industry-leading expert, allow CGRS to evaluate and complete this type of permitting for your facility.

State Construction and General Permits
A construction permit is required and will be issued for the entire facility when a source’s actual uncontrolled emissions exceeds one of the permit de minimis levels. Alternatively, some states allow a general permit that can be completed for specific emissions points in order to streamline the permitting process by accepting a pre-designed set of permit requirements.

New Source Review (NSR)
NSR is a Clean Air Act program that requires industrial facilities to install modern pollution control equipment when they are built or when making a change that increases emissions significantly.

Operating and Maintenance Plan Preparation
An O&M plan is required for all sources at synthetic minor facilities that employ emission control equipment. O&M plans ensure that the control equipment is maintained and operated regularly such that it can continually meet the pollutant destruction requirements set forth in the permit.

Source Specific and Regional Emissions Modeling
Site-specific emission factors can be mandatory in the case of higher emissions, or can be optional in the case of showing that emissions are lower than default state emission factors. CGRS collects samples in various forms, acquires licensed laboratory analyses, completes modeling, and calculates resultant emission values for reporting.

Greenhouse Gas Inventory Reporting
EPA develops an annual report called the Inventory of U.S. Greenhouse Gas Emissions and Sinks (Inventory). This report tracks total annual U.S. emissions by source, economic sector, and greenhouse gas. EPA also collects greenhouse gas emissions data from individual facilities and suppliers of certain fossil fuels and industrial gases through the Greenhouse Gas Reporting (GHG) Program. GHG must be evaluated, documented, and reported based on certain GHG emission thresholds.